Nicole O. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviews Plaintiff Nicole O.’s appeal from the denial of her application for Supplemental Security Income. The Court considers challenges to the Administrative Law Judge’s evaluation of medical opinions, residual functional capacity assessment, and treatment of migraine-related limitations. The Court affirms the Commissioner of Social Security’s final decision denying benefits.

Holdings

1. The ALJ adequately articulated consideration of the supportability and consistency factors and properly found the DDS opinions persuasive.
2. The ALJ properly considered Dr. Resnikoff's evaluation as objective medical evidence and other medical evidence rather than as a medical opinion regarding Plaintiff's ability to work.
3. The ALJ's RFC assessment was sufficiently explained and supported by substantial evidence.
4. The ALJ adequately considered Plaintiff's migraines at step three and substantial evidence supported the conclusion that they did not meet or medically equal Listing 11.02B.
5. The ALJ properly evaluated the intensity, persistence, and limiting effects of Plaintiff's migraine symptoms under the applicable two-step framework, and the findings were supported by substantial evidence.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of the DDS medical opinions under 20 C.F.R. § 416.920c.
2. Whether the ALJ properly considered the findings from Dr. Resnikoff's psychiatric consultative examination.
3. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence and adequately explained.
4. Whether the ALJ properly evaluated Plaintiff's migraines at step three, including whether they medically equaled Listing 11.02B.
5. Whether the ALJ properly evaluated the intensity, persistence, and limiting effects of Plaintiff's migraine symptoms at step four under SSR 16-3p.

Disposition

affirmed